M/S AYODHYA FAIZABAD DEVELOPEMENT AUTHORITY,FAIZABAD vs. DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

section of society for \ncommercial area as certain percentage has to be made available for local shops and \nshops for barber, vegetable vendor etc. which are disposed-off through lottery \nsystem. It is this leftover part from 5% of saleable area that is sold though auction. \nFurthermore, the disposal of residential properties is done by an Authority as per \nthe

M/S AYODHYA FAIZABAD DEVELOPEMENT AUTHORITY,FAIZABAD vs. DY. COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

section of society for \ncommercial area as certain percentage has to be made available for local shops and \nshops for barber, vegetable vendor etc. which are disposed-off through lottery \nsystem. It is this leftover part from 5% of saleable area that is sold though auction. \nFurthermore, the disposal of residential properties is done by an Authority as per \nthe

M/S K.M.GASES PVT.LTD.(NOW K.M.VYAPAR PVT.LTD),KANPUR vs. DY. CIT-VI, KANPUR

In the result, the appeal of the assessee stands allowed

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2015-16 M/S K.M. Gases Pvt. Ltd. V. The Dcit-Vi (Now Known As K.M. Vyapar Pvt. Ltd.) Kanpur 11, Moti Bhawan, 52/1, Collectorgant Kanpur (U.P) Tan/Pan: (Appellant) (Respondent) Appellant By: Shri Saurabh Gupta, C.A. Respondent By: Shri R.R.N. Shukla, D.R. O R D E R

section 143(3) of the Act, computing the total income of the assessee as under: Profits and Gains of Business or profession Net Profit (as per P&L a/c) 90,52,603 Add. 1. Dep. Taken separately 23,922 2. Demat Charges 1,796 3. Disallowance u/s 14A 18,731 44,449 90,97,052 Less- 1. Depreciation

ASSISTANT COMMISSIONER OF INCOME TAX (E), LUCKNOW vs. M/S. INDIAN INSTITUTE OF CARPET TECHNOLOGY , BHADOHI

In the result, the appeal of the Revenue is dismissed

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2016-17 Asstt. Commissioner Of Vs. M/S Indian Institute Of Carpet Income-Tax (Exemption), Technology, Chauri Road, Srn, Lucknow Bhadohi Pan: Aaaji0124M (Appellant) (Respondent) Assessee By: Sh. Akash Agrawal, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 10.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Department Against The Orders Of The Ld. Cit(A), Wherein The Ld. Cit(A) Has Deleted The Addition Of Rs.1,70,77,516/- That Was Made By The Ld. Assessing Officer On Account Of Surplus Above 15% Of Gross Receipts. The Grounds Of Appeal Are As Under: - “1. Ld. Commissioner Of Income Tax (A) Has Erred In Law & Facts By Deleting The Addition Made Of Rs. 1,70,77,516/- On Account Of Amount Surplus Above 15% Without Appreciating The Facts That The Assessee Instead Of Utilizing This Amount Or Crediting This Amount To Income & Expenditure Account, This Sum Was Directly Credited To Balance Sheet. 2. Appellant Craves Leave To Modify/Amend Or Add Any One Or More Grounds Of Appeal.” 2. The Facts Of The Case Are That The Society Is Registered Under Section 12A Of The Income Tax Act, 1961 Vide Order Dated 11.12.2006 Of The Ld. Cit, Varanasi. From A Perusal Of The Papers Submitted By The Assessee As Well As The Data Available Online, The Ld. Assessing Officer Found That There Was A Receipt Of A Grant

depreciation of Rs. 65,45,834/- in accordance with the provisions of section 11(6) of the I.T. Act, 1961. Accordingly, after these disallowances, the total income of the assessee was computed at Rs. 1,70,77,516/-. 3. The assessee went in appeal to the ld. CIT(A), Varanasi. Before the ld. CIT(A), it was submitted that

RAJDHANI NAGAR SAHKARI BANK LTD,LUCKNOW vs. DY. CIT, LUCKNOW

In the result, the appeal of the assessee in ITA

90,318/- in the P & L account.\nAccordingly, a show cause notice was issued by the Assessing Officer. The assessee\nin its reply, filed a revised computation of income in which it added back the various\nprovisions debited in P&L account and made a disallowance u/s 43B of the Income\nTax Act, 1961 (“the Act”, for short

ACIT CIRCLE 3, LUCKNOW vs. RAJDHANI NAGAR SAHKARI BANK LTD, LUCKNOW

In the result, the appeal of the assessee in ITA

Bench: Shri Kul Bharat & Before Shri Kul Bharat & Before Shri Kul Bharat & Shri Nikhil Choudharyshri Nikhil Choudharyshri Nikhil Choudharyita Nos. 112 To 114/Lkw/2024 A.Ys. 2015-16 To 2017-18 Rajdhani Nagar Sahkari Rajdhani Nagar Sahkari Vs. Dcit Bank Ltd P.K. Complex, Raja Ram Mohan P.K. Complex, Raja Ram Mohan 555Ga/86, Sardari Khera, 555Ga/86, Sardari Khera, Rai Marg, Lucknow-226001. 226001. Alambagh, Lucknow-226006 226006 Pan:Aaaar1269D (Appellant) (Respondent) (Respondent) A.Y.2016-17 Acit Circle-3 Vs. Rajdhani Nagar Sahkari Bank Rajdhani Nagar Sahkari Bank 57 Ram Tirath Marg Pratyaksh 57 Ram Tirath Marg Pratyaksh Ltd Kar Bhawan, Lucknow Kar Bhawan, Lucknow-226001 555Ga/86, Sardari Khera, 555Ga/86, Sardari Khera, Alambagh, Lucknow-226006 226006 Pan: Aaaar1269D (Appellant) (Respondent) (Respondent) Assessee By: Sh. K.R. Rastogi, C.A. Sh. Shubham Rastogi, C.A. Revenue By: Sh. Sanjeev Krishna Sharma, Addl. Addl. Cit- Dr Date Of Hearing: 28.04.2025 Date Of Pronouncement: Date Of Pronouncement: 22.05.2025 O R D E R Per Bench.: These Four Appeals Have Been Have Been Filed For The Assessment Years 2015 For The Assessment Years 2015-16, 2016- 17 & 2017-18 By The Assessee & Revenue Ssessee & Revenue Against The Respective Orders Of The Respective Orders Of The Ld. Cit(A)/Nfac, Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024 Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024. While The Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024 Assessee Is In Appeal In Assessment Years 2015 Assessee Is In Appeal In Assessment Years 2015-16, 2016-17 & 2017-18, The Revenue 18, The Revenue

90,318/- in the P & L account. Accordingly, a show cause notice was issued by the Assessing Officer. The assessee in its reply, filed a revised computation of income in which it added back the various provisions debited in P&L account and made a disallowance u/s 43B of the Income Tax Act, 1961 (“the Act”, for short

RAJDHANI NAGAR SAHKARI BANK LTD,LUCKNOW vs. DY.CIT, LUCKNOW

In the result, the appeal of the assessee in ITA

90,318/- in the P & L account. Accordingly, a show cause notice was issued by the Assessing Officer. The assessee in its reply, filed a revised computation of income in which it added back the various provisions debited in P&L account and made a disallowance u/s 43B of the Income Tax Act, 1961 (“the Act”, for short

RAJDHANI NAGAR SAHKARI BANK LTD,LUCKNOW vs. DY.CIT, LUCKNOW

90,318/- in the P & L account.\nAccordingly, a show cause notice was issued by the Assessing Officer. The assessee\nin its reply, filed a revised computation of income in which it added back the various\nprovisions debited in P&L account and made a disallowance u/s 43B of the Income\nTax Act, 1961 (“the Act”, for short

DY. COMMISSIONER OF INCOME TAX-VI, KANPUR vs. COMMERCIAL AUTOMOBILES PVT. LTD., KANPUR

In the result, the appeal of the Revenue is dismissed

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2006-07 Asstt. Commissioner Of Vs. M/S Commercial Automobiles Pvt. Ltd., Income Tax-5, Kanpur 84/105, Kailash Motors Building, G.T. Road, Afim Kothi, Kanpur-208003 Pan: Aaccc4267E (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Advocate Revenue By: Sh. R.K. Agarwal, Cit Dr Date Of Hearing: 04.11.2025 Date Of Pronouncement: 24.11.2025 O R D E R Per Nikhil Choudhary, A.M.: [ This Is An Appeal Filed By The Revenue Against The Orders Of The Ld. Cit (A)- 2, Kanpur Dated 25.09.2017, Wherein The Ld. Cit(A) Has Partly Allowed The Appeal Of The Assessee Against The Orders Of The Ld. Ao Passed Under Section 143(3) Of The Income Tax Act, 1961, For The A.Y. 2006-07 On 23.12.2008. The Grounds Of Appeal Are As Under:- “1. That The Cit(A) Has Erred In Law & On Facts In Deleting The Addition Of Rs. 5,32,366/- U/S 14A Without Taken Into Consideration That The Expenditure Incurred In Relation To Exempt Income. 02. That The Cit(A) Has Erred In Law & On Facts In Deleting The Addition Of Rs. 99,56,258/-Without Appreciating That The Provisions Of Sec. 50C Have Been Invoked By The Assessing Officer On The Basis Of Stamp Valuation Of The Property. The Assessee Has Not Claimed Before The Assessing Office To Make The Reference To The Valuation Officer U/S 55A Of It Act, 1961. 3 That The Cit(A) Has Erred In Law & On Facts Of The Case In Deleting The Addition Of Rs. 3,20,90,164/- On Account Of Loss Claimed On Sale Of Shares Without Appreciating That The Transaction As Claimed Were Sham & Was Incorporated Only To Evade The Capital Gain Earned On The Sale Of Properties. The Cit(A) Has Erred In Law & On The Facts Of The Case In Ignoring The Facts Noted By The Assessing Officer Regarding The Transaction Of Sale Of Shares.

90,164/- thereby making a total disallowance of Rs. 4,20,46,422/-. Subsequently, he allowed deduction for unabsorbed depreciation of Rs. 3,13,97,298/- and worked out the net capital gain at Rs. 1,06,49,144/-. The ld. AO thereafter proceeded to compute the book profit under section

SUBHASH JAISWAL ASSOCIATES,BAREILLY vs. PCIT BAREILLY, BAREILLY

90,54,400/- which have not\nbeen examined by the AO with regard to genuineness of the expenses\nclaimed nor whether the same were allowable as per provisions of the Act.\nThe Assessing officer has passed the assessment order on 15.12.2019 u/s\n143 of the Act without enquiries on the above issues and accepted\nsubmissions of the assessee

GURU KRIPA ASSOCIATES,BAREILLY vs. PR. CIT, , BAREILLY

In the result, the appeal of the assessee stands dismissed

90% of its sales\nwas done in cash, and even prior to\ndemonetization, the assessee had made\nhuge cash sales commensurate to the sale\nmade during the demonetization period.\nAll these explanations given by the\nassessee was rightly taken note of by the\nAO and finding anomaly to the extent of\nsubstantial increase in sales during the\ndemonetization period

SHRI RAJEEV JAIN,KANPUR vs. DEPUTY COMMISSIONER OF INCOME TAX-3, KANPUR

In the result, the appeal of the assessee is allowed

Bench: Shri. Mahavir Singh & Shri Girish Agrawalassessment Year: 2014-15 Rajeev Jain V. The Ito-3 15, Plot No.17 Kanpur Singh Engg. Compound 84/21, Fazalganj Kanpur - 12 Tan/Pan:Abfpj1327D (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Advocate Respondent By: Smt. Alka Singh, D.R. Date Of Hearing: 29 11 2022 Date Of Pronouncement: 01 12 2022 O R D E R

section 68 of the I.T. Act, this disallowance of consequential interest will not survive. Hence, we delete the addition. 9. The next issue in this appeal of the assessee is as regards to the order of the ld. CIT(A) confirming the action of the Assessing Officer in disallowing the estimated expenses at Rs.2,42,745/- @ 15%. 10. We have

HAKIKAT SARAF,KANPUR vs. INCOME TAX OFFICER-2(5), KANPUR

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary, Member A.Y. 2014-15 Hakikat Saraf, Income Tax Officer-2(5), 124/B/168, Govind Nagar, Vs. Kanpur Kanpur-208006 Pan:Afpps4419H (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Advocate Revenue By: Sh. Sunil Kumar Rajwanshi, Addl Cit Dr Date Of Hearing: 29.08.2024 Date Of Pronouncement: 29.10.2024 O R D E R Per Sh. Nikhil Choudhary: This Is An Appeal Against The Order Under Section 250 Of The Income Tax Act, 1961, Passed By The Cit(A)-1, Kanpur Dated 24.01.2017. The Grounds Of Appeal Are As Under:- “01. Because The Cit(A) Has Erred On Facts & In Law In Upholding The Addition Of Rs.47,33,000/- Under Section 56(2)(Vii)(B)(Ii) Of The I.T. Act, 1961, Which Addition Is Contrary To Facts, Bad In Law & Be Deleted. 02. Because The Cit(A) Has Failed To Appreciate The Facts & Circumstances Of The Case & Has Arbitrarily Held, That The Difference Between The Actual Gross Consideration Rs. 1,09,34,000/- & The Stamp Value Estimated By The Stamp Valuation Authorities, Subsequently Reduced By The District Valuation Officer At Rs. 1,56,67,600/- Is Deemed Income Under Section 56(2)(Vii)(B)(Ii) Of The Act.

section 271(1)(c) were also initiated. 3. The assessee was aggrieved at the addition and therefore, filed an appeal before the ld. CIT(A). Before the ld. CIT(A), the assessee submitted that nine tenants were occupying 90% of the property and had been there for 50 to 75 years. The property was a disputed property and loaded with

ACIT, RANGE-I, LUCKNOW vs. M/S APCO INFRATECH PVT. LTD., LUCKNOW

90 days, and the FDs keep\nrolling over for different LCs. The assessee was, therefore, asked to submit specific\ndetails of Bank Guarantee with accrued interest on FD allocable to the eligible\nunits.\nIn response, the assessee made the following submissions:\nImpact on profit under section 801A by direct allocation of Interest Income\nfrom FDR kept as Margin Money

ACIT, RANGE-I, LUCKNOW vs. M/S APCO INFRATECH PVT. LTD.,, LUCKNOW

90 days, and the FDs keep\nrolling over for different LCs. The assessee was, therefore, asked to submit specific\ndetails of Bank Guarantee with accrued interest on FD allocable to the eligible\nunits.\nIn response, the assessee made the following submissions:\nImpact on profit under section 801A by direct allocation of Interest Income\nfrom FDR kept as Margin Money

M/S. APCO INFRATECH PVT. LTD.,,LUCKNOW vs. ACIT-I, LUCKNOW

In the result, appeals vide I

90 days, and the FDs keep\nrolling over for different LCs. The assessee was, therefore, asked to submit specific\ndetails of Bank Guarantee with accrued interest on FD allocable to the eligible\nunits.\n\nIn response, the assessee made the following submissions:\n\nImpact on profit under section 801A by direct allocation of Interest Income\nfrom FDR kept as Margin

ACIT, CIRCLE-1, BAREILLY vs. SHRI SACHIT KUMAR AGARWAL, BAREILLY

In the result, the impugned order of learned CIT(A) is sustained, and\nthe appeal is dismissed

90,376.00\n| Gross |\n| Profit in Rs. |\n| 5,96,935.00 | 2,50,646.00 | 3,88,531.00 | 28,55,620.00\n| G.P. Rate |\n| in % |\n| 0.24% | 2.36% | 0.31% | 2.55%\nFrom the above table it is clear that the sales of the year under\nconsideration have decreased from earlier year and the G.P. rate of the\nyear under consideration

ASTT. COMMISSIONER OF INCOME TAX, LUCKNOW vs. M/S PRAG INDUSTRIES (INDIA) PVT. LTD., LUCKNOW

In the result, appeal of Revenue and Cross Objection of assessee, both are dismissed

Bench: Shri Kul Bharat, Videshri Anadee Nath Misshra

Section 40A(2) ignoring the fact that the AO has made the addition in absence of any reason provided by the assessee for the excess payment. 6. The CIT (A) has erred in law and on facts in deleting the addition of Rs.3,90,698/- made on account of disallowance of bad debt written off without appreciating the fact that